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UK income tax liability of temporary non-residents

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance

UK income tax liability of temporary non-residents

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance
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STOP PRESS: The remittance basis is abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in FA 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

The general rule is that a UK non-resident individual remains chargeable in the UK on their UK source income, subject to the limit discussed below and any provisions to the contrary in the relevant double tax treaty between the UK and the country in which the individual is resident.

As far as foreign income is concerned, usually a UK non-resident is not chargeable on this income in the UK.

However, this is not the end of the matter: the general rule on the liability to UK income tax is extended by specific anti-avoidance legislation that prevents the individual leaving the UK for a short period of time

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  • 05 Jun 2025 08:40

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